ETHI Committee Meeting
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Standing Committee on Access to Information, Privacy and Ethics
Thursday, May 19, 2022
[Recorded by Electronic Apparatus]
Welcome to the 23rd meeting of the House of Commons Standing Committee on Access to Information, Privacy and Ethics.
Pursuant to Standing Order 81(4), the committee is considering, from the main estimates 2022-23, vote 1 under the Office of the Commissioner of Lobbying, vote 1 under the Office of the Conflict of Interest and Ethics Commissioner, vote 1 under the Office of the Senate Ethics Officer, and votes 1 and 5 under the Offices of the Information and Privacy Commissioners of Canada, referred to the committee on Tuesday, March 1, 2022.
Before I welcome our witness, I'll say a couple of words.
My apologies to Commissioner Bélanger for getting this meeting going a bit late. A colleague announced his intention to resign from the House of Commons and was making a statement in the House, and I wanted to give members an opportunity to be present for that. That's why we're starting late.
We do have some committee business that we need to attend to at the end of the meeting. We had scheduled half an hour, but I don't think we need that long. I'm going to play it by ear a bit and see how we make out with questions for Commissioner Bélanger. We'll see how many rounds we need to have to get out all the questions that members may have, and then we will proceed in camera to discuss committee business.
With that, I would now like to welcome our witness. From the Office of the Commissioner of Lobbying, we have Nancy Bélanger, Commissioner of Lobbying.
Ms. Bélanger, you have up to five minutes for your opening statement.
I am very pleased to be here today to meet many of you for the first time and to speak to you about the work of the Office of the Commissioner of Lobbying.
The Lobbying Act recognizes that lobbying is a legitimate activity that should be transparent.
The Lobbyists' Code of Conduct ensures that lobbyists meet the highest ethical standards. Together, they aim to foster public confidence in federal decision-making.
This past year was another busy one for the three areas of my mandate.
The first is to maintain the Registry of Lobbyists. As the main tool for enabling transparency, the registry provides information about who is communicating with public officials and about what subjects. When individual consultants, corporations, and organizations lobby federal organizations, they must file a public registration. In 2021-22, there were over 8,000 lobbyists registered.
A report of certain oral and arranged communications with designated public office holders must also be completed on a monthly basis. Last year, there were approximately 25,000 communications. The top subject matters for the year were health, economic development and the environment.
The second aspect of my mandate is to raise awareness of the lobbying regime. This past year, we gave about 80 virtual presentations reaching more than 1,300 stakeholders, who now understand better the requirements of the act and code.
The final aspect of my mandate is to ensure compliance. We investigate allegations of non-compliance with the act and the code. A preliminary assessment is undertaken to investigate the nature of the alleged contravention and to gather some information. If I determine that further action is required to ensure compliance, I continue the investigation. When I complete an investigation under the code, I must table a report to Parliament.
Non-compliance with obligations under the act is an offence. When I investigate and have reasonable grounds to believe that such an offence has occurred, I must refer the matter to the RCMP and suspend my investigation until it has completed its process. Once this has occurred, I can cease the investigation or complete it and report to Parliament.
Last year, in addition to the preliminary assessments that were carried over from the previous year, we initiated 22 and determined that no further action was required in 14. In addition, we finalized five investigations carried over from previous years, including one report to Parliament and one referral to the RCMP. At the beginning of this fiscal year, we had 32 ongoing files.
I also decide whether to grant former designated public office holders an exemption from the five-year prohibition on lobbying when they leave office. Of the nine applications, I granted two and denied three. Two were withdrawn and two remain to be reviewed. Once granted, the exemptions are published on the office's website.
All of this work and the necessary corporate functions are performed by a very small team of about 28 employees. I want this committee to know how very proud I am of all my staff as they continue to excel during a period that has undoubtedly been challenging to us all, demonstrating adaptability, resolve and compassion.
Last November, we received additional annual funding of approximately $590,000 to increase our personnel by five employees to ensure that the registry and other IM/IT systems remain modern, secure and accessible. We have recently staffed three of those five positions.
My total budget is now approximately $5.2 million, including employee benefit payments. About $4 million of this allocation goes to salaries and benefits, leaving an operating budget of $1.2 million. About $630,000 of that amount is spent to obtain services such as HR and financial from other government institutions.
Looking ahead, I remain available should a parliamentary review of the Lobbying Act be undertaken. As you may know, I submitted a report with 11 preliminary recommendations to improve the Lobbying Act.
I will also share with you a renewed Lobbyists’ Code of Conduct. The revised code will bring a new level of clarity to the standards of behaviour expected of lobbyists. I have undertaken two phases of consultations and I expect to do one more round in the near future, before finalizing the code for your review.
Mr. Chair and committee members, those are my opening remarks. I will now gladly answer your questions.
The first questions will come from Mr. Kurek, for up to six minutes.
Thank you, Madam Commissioner, for your attendance here today. I appreciate it.
Let me just note how important it is, especially when it comes to trust in our institutions from the Canadian people, to ensure that there is a transparent, fulsome and understood lobbying regime in our country. I appreciate the role that you play in that.
I have a practical question first. I'm being mindful of the time. In terms of the workload over the course of the pandemic, was it something that you saw increased in lobbying efforts or challenges with reporting? In about a minute or so, could you outline what the ebbs and flows were during the course of COVID?
Monthly communication reports before the pandemic were about 18,000 for the year—mind you, it was an election year. During the pandemic, there were 28,000 oral communications. That, in and of itself, was an increase. We saw an increase of active registrations.
Now, everything was done virtually. Of course, oral and arranged communications.... If it's arranged in advance and it's virtual, it must be reported, so automatically the virtual world increased those oral and arranged communications. You had to plan the Zoom call. It was not something that was spontaneous on the corner of the street, which, I think, had an impact as well. For sure, there was a lot of lobbying happening.
With respect to the subject matter, health had never really been in the top two or three, and obviously it became the top two or three. Economic development was always in the top four or five, but it became the top one or two.
There was a trend in subject matter and a trend in, obviously, oral and arranged communications.
Madam Commissioner, in terms of helping to make sure that Canadians understand both your role and the role that the Lobbying Act has in ensuring that there is a high level of transparency, because of course, when there are incidents, as we have seen from time to time.... What efforts do you and your office undertake to ensure that Canadians are aware of your efforts and the work you do?
With respect to awareness, we're actually going to be working on a stakeholder engagement plan in this coming year. I find that because of the resources we have, we are much more reactive. We do go out. We speak to universities. We talk to organizations. We talk to public office holders. They understand our role. We're mainly talking to lobbyists, but we could do a lot better, and I do think that we need to start.... I don't want to say “travelling”, because it's not the right thing to say to do right now, but for sure we need to step up our engagement. Right now, it's a resource issue.
We've actually increased our international presence during the pandemic. I've done many presentations at the international level, which was really permitted because of the virtual world. We're continuing to work hard to increase our presence on social media, a little bit on our Twitter account and the Internet.
It's difficult, but I'm working on that. That is my objective in the next year.
I think my time is almost done, but I would just note that in the report that was provided to us—which, after some clarification, you provided to the committee during the second session of the last Parliament—one of the recommendations was regarding foreign lobby efforts, and I certainly think.... That's something I would just note so that it's on the record, Mr. Chair. I know there's probably no time to answer the question, but it's an important thing.
Now we go to Ms. Hepfner.
Thank you very much to the witness for the testimony today, and thank you to my colleague for starting my clock for me.
I want to go back a bit. You talked a little bit about the pandemic and how you saw an increase in requests for service, and you saw different types of requests. I'm wondering if there's more to add about how your commission was able to respond. What were the challenges in terms of remote work and pivoting to meet the demands within your own department during the pandemic?
In terms of our client services team, we have a service standard where we respond to telephone calls within 30 seconds. Those who had kids at home really had to adjust, and they did it. We continued to meet our service standards. I'm in awe of them. We somehow functioned and we did it. We're all tired, but we all did it. Everybody's tired. I get that. People were able to adapt and they continued to work hard.
At the beginning, up until October, we weren't allowed to see anybody because of the bandwidth. Everything was by Zoom but without the camera. It became a little frustrating. We were eventually able to see each other at some point. The personal aspect was tough, because we're small. We're 25 people. Families are bigger than that. We get to know everyone.
So that was a bit of a challenge, but somehow we got it done.
The biggest irritant—we have seen it in the media, and lobbyists agree with this—is the significant part of duty threshold before an organization needs to register.
The code of conduct is not the 11 recommendations. We're redoing the code of conduct. I've done two consultations, because I have to do consultations with stakeholders. A third consultation should go out next week. Then I have an obligation to submit that new code of conduct to you for your review, which I'm hoping to do in the near future.
It's difficult for me to then enforce as to whether or not somebody really did 30 hours in a month. It's a lot of work to figure that out. There really should be transparency by default, as far as I'm concerned. That's one of the biggest irritants for the community that I think this committee needs to be aware of. It needs to be a priority when there's a Lobbying Act review.
My next review, which will probably be a budget ask in the next year, I think would be for another five employees. I'm not looking to...but it's 30 people to do the same reporting burden as all other institutions, plus our mandate, which is quite demanding.
I'll say that probably it would be between five and 10, just so I don't put myself in a corner.
Now it's Mr. Villemure for six minutes.
Good morning, Madam Commissioner.
It is interesting, because I have been following the activities of the Office of the Commissioner since the beginning, that is, since 2008, when the 1989 Lobbyists Registration Act became the Lobbying Act. I believe that the first few years were devoted to the Registry of Lobbyists. People had to register and understand why they had to do so, how it worked, and so on. Now, we can see that the second and third points in your presentation are probably more important.
When we look at your website and your annual reports, we can see that there are a lot of figures: the number of people registered, the number of investigations, and so on. We also hear about your key values, but mostly about transparency. Generally speaking, you want to be transparent to inspire confidence.
Do you find that the current level of compliance is sufficient to maintain or inspire confidence?
Given that there are 8,000 lobbyists and that I have 32 files, we can say that there is compliance. There is no doubt about that.
However, that does not mean that the transparency of the current regime could not be improved. A lot of lobbying activities can take place without ending up in our registry. So I think the opportunities for improvement are related to the regime, not to compliance.
If you want to know whether unregistered lobbying is taking place, I have no such records. I have not seen any lobbying activity, whether in the media or elsewhere, that is not in my registry.
I'm not the expert on this. I have an excellent team that is working on it. So I hope to be able to give you more details the next time I come to see you.
So I did a consultation, and the feedback I got was positive. Half of the people said it was fine and clear, while others were a bit more concerned about the hospitality they could offer in the context of political activities that might affect their lobbying activities later on. So I've read everyone's comments, and we're reworking the code. I'm not aiming for perfection, but I am aiming for excellence. I really want it to be a code we can be proud of. Other countries are looking at what we are doing, so I am working very hard with my team to ensure that we have a code that contains high ethical standards for lobbyists.
Finally, earlier, you talked about clarity. What aspects do you see as needing clarity?
I'm not sure that what is reasonable for one person is also reasonable for the other. So there may be abuses. I try to make the code clear with clear indications of what is beyond the acceptable limits. That's where I'm going on the side of clarity.
I would suggest accountability; it's an interesting concept to examine.
Now, for up to six minutes, we have Mr. Desjarlais.
I want to thank our witness for being present with us today in person. It's a nice touch to be able to know exactly the folks who are doing such great work in our public service. Thank you very much for that.
You mentioned a few really interesting points related to the review. It was a review that was supposed to be regularly scheduled. The last regularly scheduled review was in 2012. That would mean five years from 2012 to 2017, so we're almost lapsed for a second review of the act. I understand the importance of your review and the work you've done in terms of your recommendations here. I think they're very good, and parliamentarians should take those concerns seriously.
I want to address one of them in particular, in relation to the final recommendation, recommendation 11. Recommendation 11 states, “Provide immunity against civil or criminal proceedings”. This is one that I want to wrap my head around to understand the motivation for your recommendation here. I think Canadians would also like to know what level of immunity these persons should be able to be protected by in order to actually do the work of advancing your office's mandate, and whether that is appropriate.
Given that experience and the understanding that other offices may be doing this, there's a slight difference in mandate, I would assume as well, so maybe it's not necessarily an oversight in that case. What concrete examples, in your experience, can you provide of prior situations where a lack of immunity impeded the work of the commissioner?
I guess we'll move to a different item related to the Lobbyists' Code of Conduct. You mentioned it at the very end of my colleague's good questions. It's here in your department plan for this current year we're in. There's a renewal and modernization process that I understand is required for this code of conduct, and there are some key initiatives. Your office actually conducted some consultations. You mentioned that they've finished the second round of three.
There is no requirement to renew the code. That was a decision on my part, because after five years of dealing with it and identifying some issues, some concerns I had with the code, I thought it was time to do it. I had also heard from the lobbyists that at the end of the day our guidance document was clearer to frame their behaviour than the actual rules themselves, so I thought, okay, we have a problem here.
The first consultation was in fact for them to tell me what they wanted me to know about how they thought the code was working. I did not have suggestions. In that round, I think I only had four responses. Then we issued a draft code, and I received 40-some comments and suggestions. There was also a template letter; I received about 180 of the same template letter.
Then I went through them all. Now we've readjusted and we are going out on the third consultation. As I was saying, I really want to get this as right as possible, so we should issue a third consultation next week.
Obviously, I would want to see in the fall if you had a reaction to it. Otherwise, it would be gazetted and then in force after that, obviously with some transition, depending on when facts occurred and when the code would be applicable. I'm hoping that in the fall or in the new year there would be a new code in place.
We've really enhanced the expectations we have from lobbyists. We've really defined it. There is no guidance required. Everything is in one package with very clear definitions, examples and standards for the behaviour.
With that, we will go to Mr. Bezan for up to five minutes.
I want to thank the commissioner for joining us today. It's great to have you here in person. I appreciate the work you do.
Now, you referred to how many cases in your tenure to the RCMP for investigation, and what were the circumstances that would require an RCMP investigation?
The file that was returned I simply closed, because it was someone who obviously did not know that they were lobbying. It was one incident. There was no reason to do a report to Parliament on that issue. If I thought that it came back and that I should file a report to Parliament, that's one option that I could do. That's the state of—
If I am of the view that the gift could be investigated under other legislation, I could suspend and refer the matter to the RCMP. I do have an obligation to suspend anything I'm doing that I believe another authority should look into. That could happen. It has never happened, but that could happen, as well.
Let's not forget that lobbyists also lobby senators and public servants. I'm not the mirror image of my colleague Monsieur Dion. I have investigations where a lobbyist might have given a gift to a public servant or to a senator. It's not always a perfect match, in that lobbyists don't just lobby members of Parliament or people who are under the jurisdiction of Monsieur Dion.
For me, it's under a code. If I do think it's something under section 121 or any other, such that I see there's been theft or fraud, I would suspend and send the matter to the RCMP under that banner.
Next it's Mr. Bains.
Go ahead, Mr. Bains, for up to five minutes.
Thank you to the commissioner for joining us today.
Several years ago, your office conducted an investigation into sponsored travel. What level of compliance did you find?
In light of that, because lobbyists were permitted to give the gifts of sponsored travel, what I ended up verifying as well was whether or not, while the lobbyists were travelling, they did lobby. When they did lobby, was it communicated on the registry? I found that it was.
Did you observe any gaps in the act?
With respect to the extent of the investigation, we were able to complete it.
You introduced two new departmental results indicators in 2020 and 2021 that still do not have targets for them determined two years later, according to your departmental plan. Why do you think it's taking so long?
We are going to continue to invest in finding ways.... We've actually just issued a survey to users of the registry to see how we can make the data more accessible. We are always looking for ways to innovate. Part of the staff we are going to get will help with that, absolutely.
You just mentioned the survey. Have those results come in?
Madam Commissioner, I only have two and a half minutes. I will ask you two questions, and if you have any additional information, you can send it to us in writing.
Gifts have always been the subject of endless discussion. How do you distinguish between hospitality, a bribe or an attempt at bribery?
I'd like you to answer in 30 seconds.
In the new code, there will be two categories: gifts and hospitality. The only gifts allowed will be to show appreciation or to thank a public office holder for performing an official function. For hospitality, I have set a limit of $30. That is all that will be allowed. I hope that by setting such a small amount, a public office holder will not be influenced in any way.
What is strange is that the Government of Canada itself gives lavish gifts worth much more than $30.
I only regulate lobbyists. The purpose of lobbyists' communications with public office holders is precisely to express their views. The word "influence" is used, but I'm always afraid it has a negative connotation. Lobbyists give their views, which is good for policy-making, but there is a limit.
I'll move on to another question.
You talked about exemptions for former public office holders. You made a few enquiries, two of which were not followed up.
Tell me a little bit about David MacNaughton from Palantir Canada. What made it not work for him?
This should be eliminated, and this is one of my recommendations. It should be equal on both sides. You can decide to leave an exemption in place, which is a matter of policy, but I don't understand this 20% limit. I might have understood it more in the case of lobbying for charities.
Some of Mr. MacNaughton's communications were not on reportable matters, but some were. I think that these communications did not even add up to two hours. They represented nowhere near 20% of his duties, so they were allowed.
It's Mr. Desjarlais for up to two and a half minutes, and maybe a little extra, given what's happened.
Thanks again to our witness for sharing her plans with us here. One of the plans I want to address is your annual report and some of the work that was in there.
I know, given the pandemic, that workers and employees in the public service have taken on an extraordinary amount of work, having to adjust their lives, having to change everything, find child care, do everything from home and be a teacher at the same time. I'm sure that your employees are very much the same.
What I also found quite disturbing, especially on behalf of labour, was that there was a survey conducted during this report, and we found that employee job satisfaction fell dramatically, from 88% in 2019 to just 65% in 2020. You identified telework as being the primary reason there was such a shortfall in the training and why it could have led to some of your employees feeling unsatisfied. How are you going to enhance training for employees, and how are you going to find a way to enhance satisfaction in terms of your employees feeling supported?
Well, first of all, we did do a lot of training in the last year to address that, so that particular annual report is from the previous year. What we have done this year is that we have created.... Each group, so the investigation team and the communications, has a community of practice where they are working with other agents of Parliament, and they really create a network.
We have done a lot of training for our investigators. We have allowed people in this virtual world to attend many international conferences and COGEL, and come to sessions where I meet with my network. We have also done mandatory training for diversity, inclusivity and mental health. I have an awesome champion of mental health. Interestingly, some of these sessions are not mandatory, and my employees are all there. I think that when we do another survey, we will have gone up again. We reduced, but that's two employees. I have 25 people, so it's, you know....
I am a great believer in an exceptional workplace, and I will do everything in my power to support people in their professional development. We ask them what they want to do and where they want to go, because I know that in a team of 25, I can't offer promotions to everybody. Sometimes we've moved people around when they're starting to feel like they want to learn something new. We do that. Luckily, people don't really leave. When they do, it's really because there's a promotion, but people enjoy working in our office, so it's good.
We're going now to Mr. Williams.
Go ahead for up to five minutes.
I'm going to start with the 11 preliminary recommendations you gave to the House for updating the Lobbying Act. It has been a year since you compiled those recommendations. Would you change any of them, or do you have any new ones?
One that I am seriously considering, and British Columbia has done this.... When in-house lobbyists lobby about contracting—not about the process of obtaining a contract, but sometimes there are conversations occurring on the side—right now that is not a registrable activity under the Lobbying Act. It is if you're a consultant, but it's not if you're in house. That's one aspect.
Another one that I think we seriously need to consider is volunteers. Of course, that's a touchy one. We're not talking about constituents who are talking to you about an issue that they're passionate about. Yukon has adopted a new rule, and I reference it in my.... It's a different document than the one I'm working on, but the Yukon has a “directing mind”, so even if someone is not paid but they're on a board of directors or they're someone who has clout, importance or decision-making powers, maybe that person should also be included in the requirements to lobby. Sometimes people will make phone calls and say, “Oh, I wasn't lobbying because I don't get paid,” but their phone call was important. I think there are some transparency gaps in that area.
Those are two, but the ones that are there I don't think I would actually change.
We have a lot more, obviously. I'm here on Zoom tonight, unfortunately. I'm sorry that I couldn't be there in person.
Did we see an increase in the last two years, during the pandemic, of lobbying through virtual meetings?
I think you talked a little bit about this, and I apologize if I'm asking about it again, but the United States, Australia and soon the U.K. will have laws around the registration of foreign lobbyists and foreign influence agents. Is the influence of foreign lobbyists something your office is concerned about?
I am aware of a bill that was tabled in the other place. I have started to look at it because I think there's some reference in that particular bill that copies parts of our registration, but not all of it. I'm going to have to study that in particular.
I think right now, if the requirements are met, foreign entities do have an obligation to register under the Lobbying Act. The problem is, if there is an allegation of non-registrable, can I enforce it? That's another question.
I first want to commend you, as a mental health advocate myself, because the way you prioritized your team in that space is really exemplary and something we should all be proud of in terms of public service, especially during the pandemic. I would just add that anecdotal piece here.
I'm going to ask a few questions about the workplace. We'll start with this, and I'm sure this is something my colleagues in the Bloc would also ask: How does the workplace embrace both official languages, both internally and perhaps with your work outside?
I like to hear that.
Moving on, in terms of workplace, management and resourcing, you mentioned earlier the need for more IT. We're in this kind of critical moment of IT staffers, more specifically data management. You mentioned you're on Twitter now and you're out there more, but you're also monitoring more. We live in this age where there's so much information and people are posting their meetings online and who they're with. Can you talk to me a little bit about that in the context of asking for more IT in your teams and how you're managing all that data in relation to tracking lobbying?
One of the persons we specifically asked for money for is in information management. She just started last month and she is there to do exactly that: train us, help us to manage all of the information that we do have in all of the systems we use. We have a registry, but we also have an investigations program, GCdocs. She's an expert in GCdocs. We are all looking forward to having her train all of our employees to make sure we keep it manageable. I used to be the deputy commissioner of access to information, so I'm very much aware of the need to make sure we keep that manageable. We're working on that too.
I'll touch on what my colleague before me asked about. Again, this is coming back to information and how we manage it, especially in the digital spaces that we're working in. We consume our news and our updates.... You mentioned earlier that you track media to know who's doing what and where, and that also relates to foreign lobbyists and foreign information.
Do you have strategies in place? Again, I'm asking this in terms of resourcing. The net is huge. The database is huge and in multiple languages and so on. What is the forward-thinking approach in making sure that you're well resourced to filter through all this information so that it's aligning with the registry and so you can continue to report well?
When we say that we look at the media, we look at the media. We start with that. We have some keywords. I might have 10 or 15 articles a day, so it's not that big. Then we go from there. We try to keep an eye out for what's going on.
As I said, we are going to be working on information management. We just hired her. We had no one. We have some cleaning up of boxes to do. We're there.
Mr. Villemure, you have the floor for two and a half minutes.
Madam Commissioner, I think that after my term as a member of Parliament, I will want to go to work for you, because there seems to be a good working climate there.
According to what you said earlier, lobbying is a way of exerting influence, it is a good thing and it must exist. I agree with you on that. However, we can see that you are setting a huge number of rules to provide a good framework for this activity.
After all this time, is lobbying well known and well understood?
I make a lot of presentations and, as soon as I say the word "lobby,” people roll their eyes. I find that unfortunate and I work hard to make people understand that it is a legitimate activity. It's the only way you can get the information you need to do your job.
So I would say that it's not always well understood. I think there is indeed an American influence that interferes with our work, but I'm working hard on that. The lobbyists who are registered in Canada know the rules. They are registered and there are not many violations of the Lobbyists' Code of Conduct.
I hope that, at some point, this perception can be improved.
I think there is still work to be done in this respect, especially in terms of understanding the details of the regime. It's all very well to talk about lobbying and the Registry of Lobbyists, but it's complicated. Sometimes people don't understand what their own obligations to the registry are.
I think there is still work to be done in this respect.
Mr. Desjarlais will have two and a half minutes. After that, I might have one or two from the chair. Then we'll wrap up, if there's no one else.
Go ahead for two and a half minutes.
Thanks to my colleagues' very good questions, I believe we have a good understanding of what your role is and the lobbying registry—or at least I understand much more, being a temporary member of this committee.
I want to back up to one of the anomalies that happened and try to better understand that. Your annual report, the 2020-21 report, delivered the largest average of active lobbyists in the history of the registry of the lobbyists. I can only imagine that was a big shock, given your capacity. You were probably already operating at a fair capacity, given the existing workload. Then there was a massive spike in workload.
Were you able to learn from that experience? Can we predict that there will be a continued increase in this pattern? Have you witnessed that pattern?
There's also, I think, a better understanding of the regime. People are showing up and registering. We get a lot of calls asking, “Should I register?” As much as we may not be out there engaging so much right now with all Canadians, I think the word is getting around. People are calling us to make sure they don't run afoul of the law. Nobody wants to end up on the front page of the news or in a file at the RCMP.
I do think that the workload is not going to reduce.
When was the initial amount in terms of a workload? I'm sure we would have to anticipate that in terms of how much work you're doing and in terms of the size of the financial envelope you have in order to conduct that work. When was that original amount?
From when the office was created until just recently, it was the same budget.
It requires work to evaluate and do a submission. We did one in 2019. I arrived in January 2018. It took me a bit of time to get my footing. Then we did a request for the IT. It's grand time that we asked for more.
I want to squeeze in a quick question, if I may. We could probably have a whole study on your 11 recommendations, but let's look at the first one. I guess I've long held that many regulations that are designed to protect the public wind up protecting incumbents in business. In other words, a large, well-capitalized organization can handle compliance a lot better than a smaller, newer one.
On the expansion to require the reporting of all activity and to do away with the threshold around the amount of activity that you do and whatnot, can you comment on whether or not there are really some winners and losers and whether or not compliance ends up making it more difficult for a small enterprise to make its case to policy-makers than a large incumbent organization?
Right now, because the threshold is where it's at, there is a lot of lobbying that's occurring that we don't know about. With the threshold of 30 hours a month, you can make four very important phone calls that have a great impact that Canadians don't know about. To me, transparency is more important than....
I put the threshold at eight hours in three months. It could be eight or it could be 10, or it could be whatever policy decision we make. You could still be doing those two or three phone calls, but at the end of the day, a lot of organizations and corporations possibly do 20 hours a month and they still don't need to register. That's too much lobbying that goes unreported, as far as I'm concerned.
Just make it a quick one. We do have other committee business, and on a Thursday, travel is an issue.
In response to Mr. Desjarlais, you said there wasn't a lot of lobbying during the election period.
Is there not lobbying that continues to be done with officials or non-elected people?
The House of Commons being the highest institution, this is a time when there is less activity.
We will now suspend while we go in camera.
[Proceedings continue in camera]